Bond issues—stamp taxes
Bond issues—stamp taxes

The following Tax practice note provides comprehensive and up to date legal information covering:

  • Bond issues—stamp taxes
  • What are the stamp taxes issues on a bond issue?
  • Tables of stamp tax consequences of a plain vanilla bond issue
  • Bearer bonds
  • Registered bonds
  • Registered bonds
  • Stamp duty on transfer
  • SDRT on transfer
  • Bearer bonds
  • Bearer instrument duty
  • More...

IP COMPLETION DAY: 11pm (GMT) on 31 December 2020 marks the end of the Brexit transition/implementation period entered into following the UK’s withdrawal from the EU. At this point in time (referred to in UK law as ‘IP completion day’), key transitional arrangements come to an end and significant changes begin to take effect across the UK’s legal regime. This document contains guidance on subjects impacted by these changes. Before continuing your research, see Practice Note: What does IP completion day mean for Tax?

This Practice Note examines:

  1. the stamp taxes that arise on issue or subsequent transfer of:

    1. bearer bonds, and

    2. registered bonds

  2. exemptions from the imposition of such stamp taxes

  3. the stamp taxes in relation to bonds issued or transferred into clearance services or depositary receipts systems, and

  4. the impact on bond issue documentation

What are the stamp taxes issues on a bond issue?

Alongside withholding tax (see Practice Note: Bond issues—withholding tax), stamp taxes on issue or subsequent transfer of a bond are a major consideration for issuers and bondholders.

While issuers generally carry the cost of stamp taxes on issue (and any such taxes would therefore represent an additional transaction cost), the burden of any charge on a subsequent transfer of a bond usually falls to the bond transferee. It is usual to clarify the stamp tax position in the tax section of an

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